ML13099A360

From kanterella
Jump to navigation Jump to search
OL - TVA Letter to NRC_03-13-2013_WBN2 Transmittal of Revised Unit 1 Unit 2 as Designed Fpr
ML13099A360
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 03/13/2013
From:
- No Known Affiliation
To:
Division of Operating Reactor Licensing
References
Download: ML13099A360 (16)


Text

WBN2Public Resource From: Boyd, Desiree L [dlboyd@tva.gov]

Sent: Wednesday, March 13, 2013 3:53 PM To: Hon, Andrew; Epperson, Dan; Quichocho, Jessie; Poole, Justin Cc: Arent, Gordon; Odell, James Hollace; Hamill, Carol L; Boyd, Desiree L

Subject:

TVA letter to NRC_03-13-2013_WBN2 Transmittal of Revised Unit 1 Unit 2 As Designed FPR Attachments: 03-13-2013_WBN2 Transmittal of Revised Unit 1 Unit 2 As Designed FPR_Final.pdf Please see attached TVA letter that was sent to the NRC today. is too large to send by e-mail. For those of you who receive a cc in the mail, the enclosure will be included with your letter on a disk.

Thank You

~*~*~*~*~*~*~*~*~*~*~

Désireé L. Boyd WBN Unit 2 Licensing dlboyd@tva.gov 423-365-8764 NOTICE: This electronic message transmission contains information which may be TVA SENSITIVE, TVA RESTRICTED, or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in civil penalties. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have receive this communication in error, please notify me immediately by e-mail and delete the original message.

1

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 793 Mail Envelope Properties (7AB41F650F76BD44B5BCAB7C0CCABFAF3EC59629)

Subject:

TVA letter to NRC_03-13-2013_WBN2 Transmittal of Revised Unit 1 Unit 2 As Designed FPR Sent Date: 3/13/2013 3:53:26 PM Received Date: 3/13/2013 3:53:32 PM From: Boyd, Desiree L Created By: dlboyd@tva.gov Recipients:

"Arent, Gordon" <garent@tva.gov>

Tracking Status: None "Odell, James Hollace" <jhodell@tva.gov>

Tracking Status: None "Hamill, Carol L" <clhamill@tva.gov>

Tracking Status: None "Boyd, Desiree L" <dlboyd@tva.gov>

Tracking Status: None "Hon, Andrew" <Andrew.Hon@nrc.gov>

Tracking Status: None "Epperson, Dan" <Dan.Epperson@nrc.gov>

Tracking Status: None "Quichocho, Jessie" <Jessie.Quichocho@nrc.gov>

Tracking Status: None "Poole, Justin" <Justin.Poole@nrc.gov>

Tracking Status: None Post Office: TVANUCXVS2.main.tva.gov Files Size Date & Time MESSAGE 908 3/13/2013 3:53:32 PM 03-13-2013_WBN2 Transmittal of Revised Unit 1 Unit 2 As Designed FPR_Final.pdf 186346 Options Priority: Standard Return Notification: No Reply Requested: Yes Sensitivity: Normal Expiration Date:

Recipients Received:

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 March 13, 2013 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391

Subject:

WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - TRANSMITTAL OF REVISED UNIT 1/UNIT 2 AS-DESIGNED FIRE PROTECTION REPORT (TAC NO. ME3091)

References:

1. TVA letter to NRC dated February 28, 2013, Watts Bar Nuclear Plant (WBN) Unit 2 - Fire Protection Report - Response to Request for Additional Information (RAI) (TAC No. ME3091)
2. Email from Justin Poole (NRC) to Gordon Arent (TVA), dated February 8, 2013
3. TVA letter to NRC dated December 20, 2012, Watts Bar Nuclear Plant (WBN) Unit 2 - Update of Commitments Associated with the Fire Protection Report (TAC No. ME3091)

This letter fulfills a commitment made in Reference 1 to submit an updated version of the Unit 1/Unit 2 As-Designed Fire Protection Report (FPR) by March 15, 2013. Specifically, this update incorporates the changes outlined in TVAs response (Reference 1) to NRCs February 8, 2013, Request for Additional Information (RAI) (Reference 2). Provided In is a listing of the sections of the FPR that were updated to address the February 8, 2013, RAI. Enclosure 2 contains a complete updated version of the Unit 1/Unit 2 As-Designed FPR. For this version of the FPR, all revision bars associated with previous updates were removed so that the revision bars in this version highlight only the changes made since the FPR version submitted via Reference 3. A red-lined version of the updated FPR was mailed on a Compact Disc (CD) to Mr. Justin Poole, NRR Senior Project Manager, on March 13, 2013.

As part of the recent discussions with NRC regarding the Unit 1/Unit 2 FPR, NRC requested a list of fire protection submittals made from the restart of the Unit 2 construction project to present day. This information is provided in Enclosure 3.

U.S. Nuclear Regulatory Commission Page 3 March 13, 2013 cc (Enclosures):

U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381

U.S. Nuclear Regulatory Commission Page 4 March 13, 2013 bcc (Enclosures):

Jesse F. Quichocho U.S. Nuclear Regulatory Commission MS 8 B1A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Fred Brown, Deputy Regional Administrator for Construction U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257

Enclosure 1 Listing of the Sections of the Fire Protection Report (FPR) that were Updated to Address NRCs February 8, 2013, Response to Request for Additional Information I. FPR Revisions for TVA Response to Questions 1 and 2 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response II 4.3 Added reference 4.3.16. Enclosure 1 Enclosure 1 VII 2.8 Updated the Justification sub-section.

Attachment 1 II. FPR Revisions for TVA Response to Question 3 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Enclosure 1 VI 3.12.9.3 Incorporates a manual action for 1-ISV-62-535 and Attachment 3 deletes the manual action for 1-ISV-62-550. Enclosure 1 VI 3.12.9.4 Attachment 4 VII 7.1.3.2 Revises the fire safe shutdown (FSSD) analysis for Enclosure 1 VII 7.2.1 Room 713-A1A. Attachment 2 VII 7.2.2 III. FPR Revisions for TVA Response to Question 4 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Revised Section 7.0 to make it applicable to Unit 1 only. Relocated information for Unit 2 Room 713.0-7.0, 7.1.3.2, A20 from Sections 7.1.3.2 and 7.2.1 to new Section Enclosure 1 VII 7.2.1, 8.4 8.4, Re-Entry into Room of Fire Origin for Unit 2 Attachment 5 Important to Safe Shutdown Operator Manual Actions.

IV. FPR Revisions for TVA Response to Question 5 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Section 7.0 was revised to address only Unit 1 Enclosure 1 VII 7.0 OMAs. Attachment 2 E1-1

Enclosure 1 Listing of the Sections of the Fire Protection Report (FPR) that were Updated to Address NRCs February 8, 2013, Response to Request for Additional Information V. FPR Revisions for TVA Response to Question 6 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Corrected reference to NRCs Agencywide Enclosure 1 II 12.10.6 Documents Access and Management System (ADAMS) accession number.

VI. FPR Revisions for TVA Response to Question 7 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Updated the data in the Evaluation and Deviation Enclosure 1 I Table I-1 columns. Attachment 7 Updated the Evaluations sub-section of the following sections of Part VI to refer to the Unit 1 evaluations in FPR Part VII, Section 7.1 and for Unit 2, Part VII Section 8.3: 3.1.3, 3.9.1, 3.12.1, 3.12.4, See 3.14.1, 3.15.1, 3.15.4,3.19.1, 3.21.1, 3.22.1, 3.23.1, Enclosure 1 VI Summary of 3.24.1, 3.25.1, 3.26.1, 3.28.1, 3.29.1, 3.30.1, 3.31.1, Attachment 6 Change 3.33.1, 3.34.1, 3.35.1, 3.36.1, 3.37.1, 3.38.1, 3.39.1, 3.41.1, 3.42.1, 3.43.1, 3.45.1, 3.46.1, 3.47.1, 3.48.1, 3.49.1, 3.50.1, 3.51.1, 3.52.1, 3.64.1, 3.65.1, 3.66.1, 3.70, 3.73.1, 3.76.1, 3.77.1, 3.78.1, 3.81.1 and 3.82.1.

Enclosure 1 VII 2.6.3.2.a Revised descriptions of fire barriers and ducts.

Attachment 8 VII. FPR Revisions for TVA Response to Question 8 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response VI 3.39.2.1 Enclosure 1 Clarified the availability of the C&A Vent Boards.

VI 3.39.2.2 Attachment 9 E1-2

Enclosure 1 Listing of the Sections of the Fire Protection Report (FPR) that were Updated to Address NRCs February 8, 2013, Response to Request for Additional Information VIII. FPR Revisions for TVA Response to Question 9 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Deleted the second paragraph under the Suppression sub-section and referenced the new Enclosure 1 VI 3.14.1 engineering evaluation (Part VII, Section 3.1.3a).

Attachment 10 Updated the Evaluations section to refer to Part VII Section 7.1.

Deleted a paragraph under the Suppression sub-section and referenced the new engineering Enclosure 1 VI 3.78.1 evaluation (Part VII, Section 3.1.10a). Updated the Attachment 11 Evaluations section to refer to Part VII Section 8.4.

New engineering evaluation associated with Part VI Enclosure 1 VII 3.1.3a Section 3.14.1. Attachment 12 New engineering evaluation associated with Part VI Enclosure 1 VII 3.1.10a Section 3.78.1. Attachment 13 IX. FPR Revisions for TVA Response to Question 10 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response Clarified the meaning of the phrase on the loss of Enclosure 1 II 12.3.3 power to the system. Attachment 14 X. FPR Revisions for TVA Response to Question 11 of NRCs February 8, 2013 RAI:

Applicable FPR FPR Enclosure and/or Part Section Summary of Change Attachment in the Revised Revised RAI Response In the table labeled NFPA 13-1975, "Automatic Sprinkler Systems" TVA System 26, Compliance NFPA Code Summary Matrix, clarified that WBN complies with Enclosure 1 X Evaluation Section 4-4.13 of NFPA 13-1975. Deleted Attachment 15 Table Section 4-4.13 from the deviation statements at the end of the table.

XI. Additional Changes Not Specifically Addressed in TVAs February 28, 2013 Response to NRCs RAI:

1. Discussed in Enclosure 4 are details on why Sections 3.85 and 3.86 of Part VI were moved to two new sections (Sections 3.70.2.2 and 3.70.2.3) in Part VI.
2. Updated the Table of Contents in Part VI to reflect the changes discussed above that affected Part VI.

E1-3

Enclosure 1 Listing of the Sections of the Fire Protection Report (FPR) that were Updated to Address NRCs February 8, 2013, Response to Request for Additional Information XII. List of Files Revised Based on the Changes Discussed Above:

Provided in Enclosure 2 is a complete copy of the FPR which contains the changes discussed above. For this version of the FPR, all revision bars associated with previous updates were removed so that the revision bars in this version highlight only the changes made since the FPR version submitted via Reference 3. For the red-lined version of the FPR that was mailed on a Compact Disc (CD) to Mr. Justin Poole, NRR Senior Project Manager, on March 13, 2013, the following files contain annotated text that depict the changes discussed above:

Adobe File Name 01 - FPR Part I 03-13-13.pdf 02 - FPR Part II 03-13-13.pdf 06 - FPR Part VI-1A 03-13-13.pdf 06 - FPR Part VI-1B 03-13-13.pdf 06 - FPR Part VI-2A 03-13-13.pdf 06 - FPR Part VI-2B 03-13-13.pdf 06 - FPR Part VI-3A 03-13-13.pdf 06 - FPR Part VI-3B 03-13-13.pdf 06 - FPR Part VI-3C 03-13-13.pdf 06 - FPR Part VI-4 03-13-13.pdf 06 - FPR Part VI-5 03-13-13.pdf 06 - FPR Part VI-6 03-13-13.pdf 06 - FPR Part VI-7 03-13-13.pdf 07 - FPR Part VII 03-13-13.pdf 10 - FPR Part X 03-13-13.pdf E1-4

Enclosure 2 Updated Version of the Unit 1/Unit 2 As-Designed Fire Protection Report (FPR)

E2-1

Enclosure 3 List of Fire Protection Submittals Made from the Restart of the Unit 2 Construction Project to Present Day Date of Subject of TVA Letter TVA Letter

1. 2010/07/16 Request for Additional Information Regarding Fire Protection Program (TAC No. ME0853)
2. 2010/08/09 Request for Additional Information Regarding Fire Protection Program (TAC No. ME0853)

Fire Protection Program (TAC No. ME0853) - Commitment to Provide Additional Information

3. 2010/08/20 on Multiple Spurious Operation (MSO) Scenarios Fire Protection Program (TAC No. ME0853) - Commitment to Provide Summary of Changes to
4. 2010/08/30 Fire Protection Report (FPR) (TAC No. ME0853)

Watts Bar Nuclear Plant (WBN) Unit 2 - Fire Protection Program (TAC No. ME0853) -

5. 2010/11/05 Commitment to Provide Multiple Spurious Operation (MSO) Evaluation Fire Protection Program (TAC No. ME0853) - Commitment to Provide Supporting Documents
6. 2010/12/01 for Fire Protection Report Amendments (TAC No. ME0853)
7. 2010/12/18 Fire Protection Program (TAC No. ME0853) - Submittal of Revised Fire Protection Report Fire Protection Program (TAC No. ME0853) - Request for Additional Information Regarding
8. 2010/12/20 the Supporting Documents Provided for the Fire Protection Report Amendments Fire Protection Program (TAC No. ME0853) - Commitment to Correct Administrative
9. 2011/01/14 Deficiencies Contained In Parts V and VI of Fire Protection Report and Re-Submit Request for Additional Information Regarding Final Safety Analysis Report (FSAR)
10. 2011/03/16 Amendment Related to Section 9.5.1 Fire Protection System (TAC No. ME3091)

Fire Protection Program (TAC No. ME0853) - Commitment to Update Fire Protection Report

11. 2011/03/16 Due to Re-Analysis and Re-Submit Fire Protection Program (TAC No. ME0853) - Submittal of Information to Address Commitment
12. 2011/03/31 In Support of Response to Fire Protection Report Request for Additional Information (RAI)
13. 2011/05/06 Request for Additional Information Regarding Fire Protection Report (TAC No. ME3091)

Fire Protection Program (TAC No. ME0853) - Submittal of Information to Address Commitment

14. 2011/05/18 In Support of Response to Fire Protection Report Request for Additional Information (RAI) and Revision to TVA March 16, 2011 RAI Response
15. 2011/05/26 Request for Additional Information (RAI) Regarding Fire Protection Report (TAC No. ME3091)

NRC Round 4b Request for Additional Information (RAI) Regarding Fire Protection Report

16. 2011/06/07 (TAC No. ME3091)

Request for Additional Information Round 5 Regarding Fire Protection Report

17. 2011/06/17 (TAC No, ME3091)

Request for Additional Information (RAI) Regarding Final Safety Analysis Report (FSAR)

18. 2011/07/01 Amendment Related to Section 9.5.1, Fire Protection System (TAC No. ME3091)

Corrosion Related Portion of NRC's Request for Additional Information (RAI) Round 6

19. 2011/07/22 Regarding Fire Protection Report (TAC No. ME3091)

Request for Additional Information (RAI) Group 6 Regarding Fire Protection Report

20. 2011/08/05 (TAC No. ME3091)
21. 2011/08/15 Transmittal of Revised Unit 1 / Unit 2 As-Designed Fire Protection Report (TAC No. ME3091)

Request for Additional Information (RAI) Group 7 Regarding Fire Protection Report

22. 2011/09/30 (TAC No. ME3091)

Request for Additional Information (RAI) Group 8 Regarding Fire Protection Report

23. 2011/10/28 (TAC No. ME3091)
24. 2011/11/21 Unit 1 - Update to the Fire Protection Report
25. 2011/11/30 Transmittal of Revised Unit 1/Unit 2 As-Designed Fire Protection Report (TAC No. ME3091)
26. 2012/03/13 Fire Protection Report - Revision of Commitments Response to Request for Additional Information (RAI) related to the Fire Protection Report,
27. 2012/04/12 Group 8 (TAC No. ME3091)

Watts Bar Nuclear Plant (WBN) Unit 2 - Response to NRC Request for Information Related to

28. 2012/04/17 Deviation 2.9 of Section VII of the Fire Protection Report
29. 2012/04/26 Transmittal of Revised Unit 1/Unit 2 As-Designed Fire Protection Report (TAC No. ME3091)

Transmittal of Revised Unit 1/Unit 2 As-Designed Fire Protection Report (TAC No. ME3091) -

30. 2012/05/09 Correction E3-1

Enclosure 3 List of Fire Protection Submittals Made from the Restart of the Unit 2 Construction Project to Present Day Date of Subject of TVA Letter TVA Letter

31. 2012/05/30 Response to Request for Additional Information (RAI) (TAC No. ME3091)

Transmittal of Revised Unit 1/Unit 2 As-Designed Fire Protection Report

32. 2012/06/07 (TAC No. ME3091)

Resolution of Concerns with Fire Protection Report (FPR) Operator Manual Action (OMA) 732

33. 2012/06/27 and Response to Requests for Additional Information (TAC No. ME3091)

Resolution of Concerns with Fire Protection Report Operator Manual Action (OMA) 732 -

34. 2012/07/19 Commitment Schedule Update (TAC No. ME3091)

Resolution of Concerns with Fire Protection Report Operator Manual Action (OMA) 732 -

35. 2012/09/13 (TAC No. ME3091)
36. 2012/12/20 Update of Commitments Associated with the Fire Protection Report - (TAC No. ME3091)

Fire Protection Program (TAC No. ME0853) - Commitment to Provide Additional Information

37. 2013/02/07 On Multiple Spurious Operation (MSO) Scenarios Fire Protection Report - Response to Request for Additional Information (RAI)
38. 2013/02/28 (TAC No. ME3091)

Transmittal of Revised Unit 1/Unit 2 As-Designed Fire Protection Report

39. 2013/03/13 (TAC No. ME3091)

E3-2

Enclosure 4 Update of the Analysis for Fire Area 64, Yard As part of TVAs response to Question 7 of NRCs February 8, 2013 RAI, changes to be made to the Evaluations sub-section of specific sections of Part VI were listed in a table in . This listing included the following:

FPR Part VI Section to be Updated Statement to be Added The feasibility and reliability evaluations for Unit 2 3.85 and 3.86 - Duct Bank A and B Operator Manual Actions are documented in Part VII, Section 8.3.55, 56, 64, and 65.

Further review of the FPR has identified a formatting error that TVA is correcting as part of this FPR revision. Table I-1 of Part I of the FPR includes Duct Bank A and Duct Bank B as part of Fire Area 64. The analysis for Fire Area 64 is documented in Section 3.70, Fire Area 64, Yard, in Part VI of the FPR; however, the evaluation of the duct banks is not included in Section 3.70 but is instead documented in standalone Sections 3.85 and 3.86 of Part VI. Typically, FPR Part VI is organized by Fire Area with the fire protection features, deviations, and evaluations for that area being followed by the Fire Safe Shutdown (FSSD) analyses for all analysis volumes contained in the Fire Area. Section 3.70 deviates from the standard organization of Part VI and requires the following changes:

1. Currently Section 3.70 is limited to AV-095, Yard, and does not include AV-097, Duct Bank A, and AV-098, Duct Bank B. AV-097 and AV-098 are currently in Part VI, Sections 3.85 and 3.86.
2. AV-097 and AV-098 are being moved to two new sections (Sections 3.70.2.2 and 3.70.2.3 respectively) and Sections 3.85 and 3.86 are being deleted.
3. The reference to the evaluations in Part VII for the Duct Banks A and B are being added to Part VI, Section 3.70.

The above changes are reflected in the version of FPR provided in Enclosure 2 and are format changes only, which do not impact the technical content of the FPR.

E4-1

Enclosure 5 Discrepancy in Supplemental Safety Evaluation Report (SSER) 18 Regarding the CO2 Concentration for the Diesel Generator Engine Rooms The following statement is made in Section 4.2.1.2, Gas Suppression System, of Appendix FF, Safety Evaluation Watts Bar Nuclear Plant Fire Protection Program, of SSER 18 dated October 1995:

(3) diesel generator engine rooms - the primary fire hazard is a surface fire (diesel fuel); therefore, the system must achieve a 34-percent concentration within 1 minute and maintain at least a 34-percent concentration for 20 minutes; As stated in TVAs response to an NRC Request for Additional Information (RAI), the design of the diesel generator engine rooms CO2 suppression system is to achieve a 34-percent concentration within 1 minute and maintain at least 30-percent concentration for 20 minutes which is accordance with the recommendations in NFPA 12-1973 (code of record). The 34-percent concentration for 20 minutes stated in the SSER is a long-standing error. To avoid future issues related to this error, TVA requests that the correction to 30-percent concentration for 20 minutes be stated in a future SSER.

Background information that supports this request is as follows:

1. Reference - TVAs letter to NRC dated May 26, 1995, Watts Bar Nuclear Plant (WBN) -

Reply to Request for Additional Information Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC NO. M63648 - ML073230886)

a. The following information is a direct quote from a portion of TVAs response (above reference) to NRC Information Request - Item 2. This information is the sixth paragraph under the heading Diesel Generator Engine Room:

The primary fire hazard in the diesel generator engine rooms is the diesel fuel. NFPA 12, Section A-223 (Attachment 2) states, "Proper selection of the type of fire that the system should be designed to extinguish is important and, in many cases, will require sound judgment after careful consideration of all the various factors involved." One of those factors is, "Will a deep seated fire develop, considering the speed of detection and application of the contemplated system?" The expected fire will be a Class B fire (i.e.,

diesel fuel). A diesel fuel oil fire is a surface type fire. The applicable section of NFPA 12-1973 is Section 23, "Carbon Dioxide Requirements for Surface Fires" and Section 25, "Distribution System." Since the diesel generator engine rooms also contain the generator, Section 2534 (rotating electrical equipment) is applicable and the acceptance criteria was revised to require that a CO2 concentration of at least 30% be maintained for at least 20 minutes. This new acceptance criteria is more conservative than the original design basis criteria and has been achieved as demonstrated by testing (Attachment 6). (emphasis added)

b. The referenced May 26, 1995, TVA letter also states that a full discharge CO2 test was conducted on March 3, 1995. The records from the March 3, 1995, test were provided as attachments to TVAs May 26, 1995, letter to validate the stated performance of the system.

E5-1

Enclosure 5 Discrepancy in Supplemental Safety Evaluation Report (SSER) 18 Regarding the CO2 Concentration for the Diesel Generator Engine Rooms

2. Reference - Unit 1 System Description N3-39-4002, CO2 Storage, Fire Protection, and Purging Reference - Unit 2 System Description WBN2-39-4002, CO2 Storage, Fire Protection, and Purging
a. Provided below is the wording from Sections 6.0 and 6.1 of the Unit 1 System Description referenced above. The wording for these sections of the Unit 2 System Description is essentially the same. These documents establish the parameters which must be met during system testing and for compliance with applicable sections of the NFPA code of record (NFPA 12-1973) for WBN Unit 1 and Unit 2:

6.0 MAINTENANCE AND TESTING COMMITMENTS Valve testing and inspection requirements are documented in the Fire Protection Report,Section II. This program ensures proper valve alignment and operability. If full scale discharge testing to verify concentration is to be performed, see Revision 4 of this system description.

6.1 Acceptance Criteria The Diesel Generator engine rooms are considered as surface fire areas. The generator is considered as rotating electrical equipment; therefore, the hold (soak) time for rotating equipment will also be applied to these rooms. NFPA 12-1973 acceptance criteria is as follows:

  • Design concentration shall be a minimum of 34%
  • Design concentration shall be achieved within 1-minute
  • A minimum concentration of 30% shall be maintained for a minimum of 20-minutes E5-2